On 23 April 2026, the Council of the European Union (the “Council“) adopted its 20th package of sanctions against Russia (the “20th package“) in response to Russia’s ongoing war against Ukraine. The new sanctions include robust energy measures, as well as the first-ever activation of the EU’s “anti-circumvention” tool. The package also targets financial services, including payment services and crypto asset services.
The package was implemented principally through Council Regulation (EU) 2026/506 of 23 April 2026 amending Regulation (EU) No 833/2014 and Council Regulation (EU) 2026/511 amending Regulation (EU) No 269/2014. Similar sanctions provisions in respect of Belarus have been set down in Council Regulation (EU) 2026/513 amending Regulation (EC) 765/2006.
In this article, we have summarised the key points contained in the 20th package.
1. Payment services
The 20th package introduces a prohibition on transactions with agents in Russia and other third countries that offer to facilitate international transactions from Russia in order to bypass EU sanctions. EU payment service providers should carry out sufficient due diligence to ensure that any intermediary or agent involved in cross-border payment transactions does not fall within scope of this new prohibition.
2. Crypto-asset services
The 20th package introduces a total sectoral ban on carrying on business with any Russian crypto-asset service provider (“CASP”), as well as any Russian decentralised finance platforms enabling crypto trading, in light of their use in circumventing EU sanctions. The new measures also prohibit the use and support of the cryptocurrency RUBx, a rouble-backed stablecoin, as well as the digital rouble, a digital currency under development by the Central Bank of Russia and which is suspected by the EU of being set up to enable sanctions circumvention. This builds upon earlier EU sanctions against other popular rouble-backed stablecoins.
The 20th package builds upon the 19th package’s provisions which stopped the provision of all regulated crypto-asset services as defined under the EU’s Markets in Crypto Assets Regulation and now extends that prohibition to unregulated de-fi platforms and targets state-sponsored digital currencies issued by the Russian state. EU firms active in the crypto-asset industry should review their existing client relationships and product offerings carefully in light of these developments as effectively any crypto-asset services irrespective of status under EU regulation are now prohibited.
Questions remain as to how EU firms should manage the return of assets to impacted clients, given the layered and wide-ranging restrictions now in place across payment, e-money and crypto-asset channels.
3. Banking and other financial sector restrictions
The 20th package extends the ban on EU credit institutions conducting business with twenty additional Russian banks, bringing the total number of Russian banks excluded from access to the EU internal market to 70. The transaction ban is also extended to four banks in Kyrgyzstan, Laos, and Azerbaijan that assist the Russian war effort by significantly frustrating sanctions or connecting to the Russian System for Transfer of Financial Message (SPFS), the Russian banking messaging network setup as an alternative to SWIFT. Five third-country financial entities are de-listed following receipt of commitments that those entities will not engage in the activities for which they were listed.
4. Energy measures
The 20th package lists an additional 46 shadow fleet vessels, bringing the total to 632 vessels subject to a port access ban and a ban on receiving services, alongside a significant maritime insurer. Safeguards on tanker sales from the EU to prevent Russian end-use are introduced, including a mandatory ‘no Russia’ clause in sales contracts. For the first time, a third-country port, the Karimun Oil Terminal in Indonesia, has been listed, alongside two Russian ports. The package also establishes the legal basis for a future maritime services ban on the transport of Russian oil and petroleum products, to be introduced in coordination with the G7 and the Price Cap Coalition, with the Council to decide on its entry into force.
5. Anti-circumvention measures
In a significant first, the EU has activated its anti-circumvention tool against the Kyrgyz Republic due to its systematic and persistent failure to prevent the onward transfer to Russia of certain machine tools and telecommunications equipment used in the manufacture of drones and missiles.
The 20th package also adds 60 entities to the list of those providing support to Russia’s military-industrial complex or engaged in sanctions circumvention, including 32 entities established in Russia and 28 entities established third countries including China (including Hong Kong), Türkiye, the United Arab Emirates, and Thailand.
6. Legal protection of EU firms
The 20th package adds further legal protection for EU firms against retaliatory actions of the Russian Government, allowing Member State courts to fine Russian parties that launch abusive lawsuits before Russian courts, and enabling EU firms to claim damages arising from the enforcement of abusive judgments in third countries. The package also introduces a transaction ban against Russian competitors taking advantage of de facto illegitimate expropriations of EU firms, as well as those who use the intellectual property rights of EU firms in Russia without their consent.
7. Alumina exports from Ireland
The scope of the 20th package had attracted media attention in Ireland in the context of recent scrutiny of alumina exports from Ireland to Russia. Whilst the 20th package introduces new import bans on a range of metals, chemicals and minerals worth over €530 million, alumina does not feature among the newly restricted goods. EU firms and stakeholders with exposure to this sector should monitor developments in future sanctions packages closely as the position could change in future.
8. Overall assessment
The 20th package represents a further significant escalation of economic pressure on Russia, spanning energy, finance, trade and anti-circumvention, and is notable for several landmark measures including the first-ever activation of the EU’s anti-circumvention instrument and the establishment of the legal basis for a future maritime services ban. For clients in the financial services industry, the extension of the crypto ban to decentralised platforms, new restrictions on payment agents, and the expansion of the banking transaction ban to 70 institutions all demand careful attention.
Contact us
We are continuing to keep a close eye on developments in this area and will publish further updates as matters progress. For further information on the 20th package and sanctions more generally please contact Joe Beashel, Ian O’Mara, Adam D’Arcy or your usual Matheson contact.
This article is provided for general information purposes only and does not purport to cover every aspect of the themes and subject matter discussed, nor is it intended to provide, and does not constitute or comprise, legal or any other advice on any particular matter.